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EPR compliance for Germany and France

As the EPR registration obligation deadline approaches, sellers are beginning to have more questions about EPR. How are EPR products classified? How do sellers calculate the quantity that their store needs to declare? What issues should be paid attention to when submitting the registration to the platform?

We conducted a comprehensive interpretation and analysis of the EPR registration issues that cross-border sellers are mostly concerned about.

What is EPR product classification?

EPR product classification is the basis for EPR registration. After understanding the product classification, sellers need to clarify which EPR product classifications they need to register. Each different product classification needs to go to different recycling operator for registration and declaration.

I have already fulfilled some EPR obligation, do I need to inform the platform?

Yes, please provide your EPR registration information to the platform. Amazon will share the link for uploading the EPR registration in the fourth quarter of 2021.

How do sellers calculate the quantity that their store needs to declare?

The seller needs to calculate the specific recycling volume that the agency company needs to declare to the recycling operator:

Recycling amount = the quantity/weight of the products sold in the store in the current year under the EPR category

For example: Seller’s store has ten toys for sale, and the total number of the ten toys is expected to be 5000.

What information should be provided to buyers’ products after EPR registration?

  • After the seller has registered for the EPR, it is also necessary to place relevant information or marks on the products to the consumers, including but not limited to:
  • Print the trash bin logo on the electronic and electrical products and packaging sold.
  • Print the recycling registration number on the sales invoice.
  • Mark the French packaging recycling operator logo on the packaging cartons.
  • French electrical and electronic sellers need to list the term of environmental protection payments on their invoices.

What should I pay attention to when submitting the registration to the platform?

The seller receives the registration information of each EPR product category and submits it to Amazon backend for review.

Different EPR product categories have separate registration numbers.

The WEEE submission number in Germany is not a registration number for package and cannot pass the review.

What is the lead time for EPR registration?

  • German packaging law: 2 weeks
  • German electrical and electronic law and battery law: 6-12 weeks
  • German WEEE registration is generally slow.

What are information requirements for EPR registration?

  • Business license
  • Store information
  • Product information
  • The number of products sold
  • VAT tax number or tax identification number

What should the seller do after receiving the EPR registration reminder email from Amazon?

  1. Check whether the products produced or sold by oneself meet the EPR commodity classification;
  2. Confirm that the products you produce or sell involve several categories;
  3. Calculate the quantity that needs to be declared for your related stores;
  4. Registration of the relevant laws and regulations, and put relevant marks on the products and packaging, and declare regularly;
  5. Fill in the registration confirmation on the platform (generally: registration certificate and registration number).

How should sellers respond to this EPR policy?

Some people might ask, the EPR regulations have only come into effect this year, so we don’t need to deal with it in a hurry now? Then answer is No. The number of sellers registration will increase at the end of this year, so the review time could be much longer. When the review peak period occurs, it is too late to register and update your EPR information.

What are the consequences of not registering for EPR?

This email notification clearly requires that starting from 2022, for products sold by sellers to Germany or France, Amazon will confirm whether the products sold by the seller meet the EPR requirements of the country/region,  collect and verify the seller’s EPR registration information.

If the seller’s products cannot prove that they meet the requirements of the EPR, Amazon will impose a suspension on the seller’s products listing.

If the German authority find that the seller’s goods do not meet the EPR requirement in Germany, they could face goods detention and fines.

There are only three months left until the implementation date of 2022. Amazon will also share the link for uploading the EPR registration information in the fourth quarter of this year. Please noted that sellers on the German site need to register for EPR as soon as possible to avoid products delisting.